ML18092A056

U.S. Department of Energy West Valley Demonstration Project (DOE-WVDP) Responses to U.S. Nuclear Regulatory Commission (NRC) Comments on DOE-WVDP Main Plant Process Building (Mppb) Decommissioning & Demolition (D&D) Plan

ML18092A056
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	02/05/2018
From:	Bower B US Dept of Energy, West Valley Demonstration Project
To:	Amy Snyder NRC/NMSS/DDUWP/MDB
AMSnyder NMSS/DUWP/MDB 415.6822 T5D48
References
Download: ML18092A056 (10)

Text

Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799 I

February 5, 2018 Amy Snyder, Senior Project Manager Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Rockvilie, MD 20852-2738

SUBJECT:

U.S. Department of Energy West Valley Demonstration Project(DOE-WVDP)

Responses to U.S. Nuclear Regulatory Commission(NRC)Comments on DOE-WVDP Main Plant Process Building(MPPB) Decommissioning &

Demolition(D&D)Plan, WVDP-586,Rev. 1, dated February 27, 2017

REFERENCE:

Letter(374925), A. Snyder to B. C. Bower,"U.S. Department of Energy West Valley Demonstration Project Main Plant Process Building Decommissioning

& Demolition Plan, WVDP-586, Revision 1 (Docket No. 05000201 (POOM-0032))," dated September 28, 2017.

Dear Ms. Snyder:

DOE-WVDP responses to the NRC comments on the MPPB D&D Plan are provided in the enclosed table. After all comments have been resolved to NRC's satisfaction, the WVDP MPPB D&D Plan(WVDP-586) will be finalized and a copy will be provided to you. Our goal is to have the Plan issued in March 2018.

Please contact Moira Maloney of my staff at(716)942-4255 if you have any questions or need additional time for your review.

Sincerely, C. Bower, Director West Valley Demonstration Project

Enclosure:

Comment and Response Table for the NRC Comments on the WVDP MPPB D&D Plan cc: See Page 2 JF:377509-450.4

Ms. Amy Snyder February 5,2018 cc: S. W. Chase, CHBWV, WV-IOPLEX, w/enc.

T. D. Dogai, CHBWV, WV-IOPLEX, w/enc.

D. P. Klenk, CHBWV,WV-IOPLEX, w/enc.

R. E. Steiner, CHBWV,WV-PL6, w/enc.

M. N. Maloney, DOE-WVDP, AC-DOE, w/enc.

Z. Z. Zadins, DOE-WVDP,AC-DOE, w/enc.

A. Snyder, NRC,w/enc., amv.snvder@,nrc.gov P. Bembia, NYSERDA,AC-NYS, w/enc.

JF:377509-450.4

U.S. NUCLEAR REGULATORY COMMISSION STAFF COMMENTS ON WVDP MAIN PLANT PROCESS BUILDING DECOMMISSIONING & DEMOLITION PLAN, REVISION 1. WVDP-586 Comment NBC Comment WVDP Response Number

1) Page 15 of 94 1. The activity levels identified in Table 2 are total activity/1 OOcm^ (fixed "Table 2 shows an example of radioactivity levels for several areas plus removable). Surfaces of the facility are being painted (i.e., fixative based on the characterization data. Data collected are utilized for applied) before MPPB demolition to bring the remaining loose activity dose modeling to support demolition sequencing and limits (i.e., levels down below 2,000 dpm/IOOcm^ Alpha and 100,000 maximum number of square feet in a given area that can be dpm/1 OOcm^ beta-gamma.

removed or demolished in a given time period).... Radiological surveys and samples continue to be collected to characterize and 2. Due to the condition of the surfaces in many locations, such as:

make a determination that each area is ready for demolition." original paint intact, stainless steel liner present, etc., the activity is generally considered to be present on the surface. Many areas were Comment 1: Please clarify the removable fraction for the surficial sampled by drilling or coring into the concrete surface approximately concentrations listed in Table 2. Please clarify what efforts were three-quarters of an inch, where the activity stopped at most locations.

made to determine If the materials are volumetrically contaminated These samples were screened with field instruments and then sent to (e.g., provide additional detail on sampling and measurement an onsite laboratory for isotopic analysis. For some areas where methods). multiple layers of grout had been placed over the years for shielding, full-thickness cores were taken through to the ceiling of the area below and the cores were analyzed in a laboratory for total activity.

2) Page 15 of 94 The scope of work for this phase of demolition (Phase 1 A)includes removal of "Also, grout will be placed in below-grade portions of the MPPB and the MPPB to the first floor slab (nominal 100 +/- 3-ft reference elevation). The on the 100 foot plant elevation floor (i.e., ground level) prior to first floor slab and stub walls are intended to remain intact to help control storm demolition, as necessary to reduce the radiological dose to workers water and to prevent surface water infiltration into the subsurface cells and soil.

and provide a protective barrier during demolition. Additional material such as gravel may also be used to protect the underlying The grouted surfaces and additional material serve as a protective barrier to surfaces." prevent damage to the first floor slab and below-grade structures and control "Information on residual radioactivity levels of these surfaces will be the potential for contamination to migrate from these surfaces during and collected prior to grouting, but this radioactivity is not included in the following Phase 1A demolition. All parts of the MPPB slab and below-grade dose modeling to support open air demolition since the surfaces will structures/foundations will be removed during the next phase of demolition not be disturbed during this demolition." (Phase IB).

Comment2:At this point in the document, it is unclear what portions The first sentence referenced will be revised as follows; "Also, grout will be of the MPPB will remain at the end of the demolition. Clarify the placed in below-grade portions of the MPPB and on the 100 foot plant intended disposition of the grouted surfaces; and whether the elevation floor (i.e., ground level) prior to demolition, as necessary to reduce grouted surfaces will remain or will be removed during this or future the radiological dose to workers and provide a protective barrier to prevent demolitions to provide support for the statement that the inventory on damage to the first floor slab and below-grade structures during and following the surfaces will not be included In dose modeling because the demolition."

surfaces will not be disturbed during demolition. Clarify what is meant by providing a "protective barrier"(i.e., the grout serves as a The following sentence will be added at the end of the referenced paragraph barrier to prevent damage to below-grade or 100 foot plant elevation on page 15: 'The below-grade portions and remaining grouted, ground-level surfaces from demolition of above-grade portions of the MPPB, surfaces of the MPPB will be removed during a subsequent phase of and/or to prevent release of radioactivity). demolition."

The attached figure showing a plan view following demolition will also be added WD:2018:0081

to the Plan to compliment Figure 25 which shows a cross-sectional view.

3) Page 15 of 94 The method for estimating activity in Main Plant areas was predicated on the

'Table 3shows the radioactivity levels in two of the areas of the nature of contamination In the area under consideration. In areas with low MPPB (Process Sample Cell-2 and Extraction Cell-2) where data gamma background radiation and In which contamination had not been have been collected and the determination made that the areas are previously fixed through the use of paint or other fixatives, direct gross alpha ready for demolition. This Is an example of the data that will be measurements were used to quantify the area! concentration of alpha collected for the various areas of the MPPB and used to determine contamination in the cell. For areas with elevated background radiation or in that the overall building Is ready for demolition with the areas in which fixative had been applied, surface beta/gamma dose rates were implementation of appropriate radiological controls. Calculations used to infer Cs-137 contamination levels. In both methods, estimates of using AERMOD and the radioactivity levels for a given area are indicator parameters(Am-241 in the former and Cs-137 in the latter) were performed to show that the remaining activity levels are below the correlated to the concentration of other nuclides through the use of scaling maximum that can be left behind to comply with worker dose limits." factors derived from historical sampling results. Finally, areas exhibiting very high background radiation fields were characterized through the use of sample Comment 3: Data in Table 3appear to be based on CS'137 collection and analysis.

concentrations and the use ofscaling factors. Please clarify the basis for and expected error associated with use ofscaling factors. The Main Plant characterization process ensured a conservative bias for estimation of area material at risk (MAR). A stratified random sampling process was employed for each wall surface to identify five survey locations. Within each survey location the area of highest contamination was identified and smear surveys were obtained to determine alpha and beta/gamma contamination levels to aid in validation of the nuclide distribution chosen for characterization. Direct readings for alpha and/or beta/gamma contamination were also obtained depending on background or surface condition in order to further validate the selected nuclide distribution. Although statistical uncertainties were not developed for these estimates, the use of maximum measured values for cell characterization is believed to have introduced adequate conservatism in the analysis.

No change to Plan.

4) Page 26 of 94 At this time, no use of enclosures or portable ventilation controls is planned The demolition approach may include the limited use of localized, during MPPB demolition. If such controls are required during demolition, it will portat>le ventilation controls to insure worker protection and public be based on the Radiological Engineering Department's analysis of worker health and safety." safety monitoring and controls and details will be provided in a Work Instruction Package(WIP). Conditions requiring the use of temporary Comment4:Elaborate on exactly what conditions would require use enclosures/ventilation would include radiological activity levels at the WVDP of temporary enclosures/ventilation during the decommissioning. perimeter fence line that would not allow open air demolition to continue (i.e Specifically, is this approach expected to be necessary during >0.02 DAG) '

demolition of the structure vs equipment contained within,the structure? Ifso, the plan should include more detail on this subject. The following sentence will be added after the sentence referenced in the comment: The details of such localized controls would be based on the specific area and nature of the radioactivity/contamination levels present and would be included in a WIP."

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Comment NRG Comment WVDP Response Number

5) Page 27 of 94 The approach for water collection, including water used for dust suppression, "Run-off water will be controlled and dispositloned in accordance and management will be described in an appendix to the WIP and is with WVDP procedures (e.g.. treated and discharged through the summarized below.

site's State Pollutant Discharge Elimination System [SPDES]

permitted system). A berm or berms will be set up around the Water control barriers will be in place prior to and maintained during all phases demolition area(s)to provide containment for dust suppression water of demolition and set up around the demolition area to provide control and and precipitation. The water will be tested as directed by site containment for dust suppression water and precipitation. As currently procedures and transferred for treatment through the SPDES envisioned, demolition and storm water retained behind the barriers (e.g.,

permitted low-level waste treatment facility. Efforts will be made to berms) would be pumped to collection tanks, sampled, and transferred for minimize the volume of water by using misting techniques and a treatment through the WVDP low-level waste treatment facility, or othenwise surfactant. Storm drain inlets within the bermed area will be sealed. dispositioned based on the sample results.

These practices will effectively control the volume of water to be controlled, as well as avoiding impacts to other systems, including The sentences identified in the comment will be revised as follows:

groundwater. to minimize the potential for the spread of "The water will be pumped into collection tanks, sampled and transferred for contamination both inside and outside work areas." treatment through the SPDES permitted low-level waste treatment facility, or othen/vise dispositioned based on the sample results. Efforts will be made to Comment5:Please further explain in the plan how water will be minimize the volume of water by using misting techniques and a surfactant.

collected for testing and how groundwater impacts will be mitigated. Storm drain inlets within the bermed area will be sealed. Minimizing the volume of dust suppression water and pumping collected water from the containment area will mitigate potential impacts to groundwater and minimize the potential for the spread of contamination both inside and outside work areas."

6) Page 27 of 94 The scope of work for this phase of demolition (Phase 1A)includes removal of "The MPPB floors and below-grade structures will be coated with a the MPPB to the first floor slab (nominal 100 +/- 3-ft reference elevation). The fixative and/or grouted, as necessary to maintain dose ALARA, first floor slab and stub walls are intended to remain intact to help control storm protect the surfaces from damage during demolition, minimize water and to prevent surface water infiltration into the subsurface cells and soil.

equipment contamination, and deter water intrusion. Prior to placing grout, an engineering analysis will be performed to determine the In addition to the grout placed prior to demolition, a cover which may include thickness of grout needed to avoid damage to the underlying soil, gravel, and a membrane will be used to limit water intrusion and protect surfaces. Items such as filters, cell debris, piping, and miscellaneous the structural integrity of the first floor slab and below-grade structures during equipment with high levels of radioactivity will already have been and following Phase 1A demolition. All parts of the MPPB slab and below-removed from the building or stabilized during deactivation." grade structures/foundations will be removed during the next phase of demolition (Phase IB).

Comment6: Because the plan does not particularly address the decommissioning of the sub-grade structures nor provide any The following sentence will be added at the end of the first paragraph on page schedule for their being addressed, elaborate on how the site wiil be 28: "The below-grade portions and remaining grouted, ground-level surfaces secured/stabiiized once the decommissioning in accordance with the of the MPPB will be removed during a subsequent phase of demolition."

plan is complete. Specifically, will the sub-grade structures be enclosed, ventilated, and a mechanism provided for water extraction The length of time until the first floor slab and below-grade structures are should it be necessary? If any such approaches are needed, how decommissioned has not yet been determined.

long will they be needed before the sub-grade structures are decommissioned? ifsuch approaches are not needed, explain why. The GPC cell structure is a below grade cell that will be sealed, and the ability to connect ventilation will be maintained. At this time, ventilation is not planned Page 28 pf 94 to be reconnected to the GPC.since it is not anticipated to be needed for If necessary, additional fixatives can be applied during the demolition radiological controls prior to the next phase of MPPB demolition. The work process. capability to detect the presence of water will exist in the GPC. but no visual WD:2018:0081

Comment NRG Comment WVDP Response Number access or water removal system will be in place, since this is not believed to be Comment: The plan should describe the types ofsituations or necessary prior to the next phase of MPPB demolition. Additional controls conditions that would cause additional fixatives to be applied. would be implemented if determined to be necessary during routine radiological surveys and monitoring.

Similar to the approach for VIT, details for when to consider the application of additional fixatives will be identified in the MPPB demolition WIP. Examples may include removed building materials that require additional processing at a later time or demolition debris that is staged, awaiting packaging into waste containers on a subsequent day.

The use of additional fixatives may also be considered based on monitoring during demolition and/or waste loading.

A sentence will be added to indicate that application of fixative will be considered for demolition materials that require further processing on the ground or are awaiting packaging Into waste containers.

7) Page 57 of 94 The radiological monitoring plan in the WIP will identify locations and set points

'The WIP will include a radiological monitoring plan with action similar to the approach currently being implemented for VIT facility demolition.

levels. There will be alerts set up on the Continuous Air Monitors The CAMs will be used for real time monitoring and will measure Alpha and (CAMs)that will alert the workers before a "stop work" level would be Beta/Gamma activity. The quantity of CAMs and their locations are being reached. Based on such an alert, the ongoing work will be evaluated evaluated and will be identified in the final WIP.

to determine if the increase in activity is anticipated and what actions, if any, may be needed." A minimum of four CAMs will be located along the 30 meter contamination area boundary. The CAMs are typically located in small weather enclosures, with Comment 7: The plan should clarify how the CAMS will be utilized. their status continuously monitored by a Radiological Controls Technician.

For example, what exactly will the CAMs be used to monitor(alpha, Additional CAMs will be located between the contamination area boundary and beta/gamma, etc.); how will the action leveis be established: explain the boundary of the radiological buffer area, as well as beyond the buffer area whether the action levels will address all radionuclides potentially boundary.

emitted: and explain where these CAM units wili be located relative to the actual work that will occur under this work plan? A Radiological Engineering calculation will be performed to determine the CAM set points to maintain levels <3 DAC-hour per day in order to not exceed 12 DAC-hour during a 4-day, 40-hour work week. If additional days are required to be worked, an evaluation of the air monitoring data would be required by Radiological Engineering to ensure a 3 DAC-hour buffer exists for the day(s) to be worked.

Similar to the approach for VIT demolition, no action levels are established for tritium or iodine-129.

Text will be added to the plan to indicate that CAMs will be used for real time monitoring and will measure Alpha and Beta/Gamma activity along the approximate 30 meter contamination area boundary and also at locations bevond the contamination area boundary.

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Comment 1 . ^

WVDP Response Number I NRG Comment

8) Page 58 of 94 Similar to the previous response: The radiological monitoring plan in the WIP "Contamination surveys at the 30 meter perimeter locations will be will identify locations, set points, and survey methods similar to the approach performed during demolition, and demolition equipment will also be currently tieing implemented for VIT facility demolition. A minimum of four(4) surveyed." real time air monitors(CAMs) will be located along the 30 meter contamination area boundary and additional text will be added to the plan.

Comment8: The plan should provide a more detailed description of the 30 meter perimeter sampling locations and contamination survey Contamination surveys will be performed in accordance with RC-RPO-104, methods. "Performing Radiation and Contamination Surveys," with additional details 1

identified in the MPPB demolition WIP.

9) Page 60 of 94 The plan will be revised to clarify that "perimeter" refers to the site perimeter or

'The action levels at the perimeter of the site will be 0.02 Derived Air the WVDP security fence that is referred to in the first paragraph of Section Concentration(DAC)which is the maximum weekly average 6.5.

concentration according to the AERMOD calculation and activity on the deposition mats of 20 dpm/100cm2 alpha and 1000 dpm/100cm2 The description of the boundaries in section 6.5 will be revised for clarification beta-gamma." and to remove "perimeter"from the descriptions. Figure 27 will be removed to help alleviate any confusion and since the boundary descriptions are being Comment 9:Several times in the plan, the "perimeter"is referred to revised as follows:

rather ambiguously. Please clarify in the plan, when not already specified, whether the perimeter being discussed is the demolition Contamination Area/Monitoring Boundary - Approximately 30 meters from the "boundaries"(demolition work site perimeter?)as discussed on active demolition zone. CAMs will be located at this boundary to ensure worker pages 61 and 62 of the plan, the V\NDP perimeter as discussed on protection levels are achieved.

page 61, or has some other meaning.

Buffer Area Boundary - Approximately 90 meters from the active demolition zone to keep unauthorized persons away from demolition activities and supporting functions.

10) Page 63 of 94 The WVDP does not release program implementing procedures. WM-210 "Radiological Characterization of the demolition debris will also be Waste Stream Characterization, WM-250 Waste Container Characterization, conducted in accordance with WM-210, Waste Stream and WM-230 Determining Radioactivity in a Package can be reviewed at the Characterization for the demolition waste streams and to establish site.

the isotopic scaling factors for the waste. Characterization of the IM containers or other containers of demolition debris will be performed The following will be added to Section 7.1.2: "Waste package in accordance with WM-250, Waste Container Characterizations and characterizations will utilize the same unit-by-unit source term estimates being WM-230, Determining Radioactivity in a Waste Package." prepared to substantiate the acceptability for open-air demolition. The disposition of each unit/component will be tracked to individual waste packages Comment 10: Please provide WM-210 and WM-250 to NRC for and summed to provide the total radioactivity content of a given package."

review or otherwise the plan should provide additional details on characterization of the waste and waste packages destined for disposal.

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Comment Number NRG Comment WVDP Response

11) General The forms attached to WVDP-586 are not specific to the Plan, but are part of Comment 11: Because the site has fissile materials and it is the standardized WVDP Integrated Safety Management Review of any apparent that Nuclear Criticaiity Safety(NCS) will be considered proposed activity at the site, including preparations for demolition. The Main from the attached forms in the plan, the plan should provide a Plant Process Building is being prepared for open air demolition and therefore general overview of the NCS program and qualifications of the fissile material content in the facility has been reduced to levels consistent personnel performing this function sufficient to assure that NCS wiii with residual surface contamination. Estimates of fissile material in the facility, be appropriately addressed during the implementation of the hAain as indicated in the draft Documented Safety Analysis currently with DOE for Plant Process Building work plan. review, indicate that approximately 2650 fissile gram equivalents(FGE)of Pu-239 remain in the entire facility. Approximately 75% of this fissile mass Is low enriched U-235.(The effective enrichment of residual material in areas of the MPPB is less than 2 weight percent U-235.)There are no known significant holdups of material remaining in the facility.

The attached text will be added as a new section 4.2 to provide an overview of the Nuclear Criticaiity Safety proqram.

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Attachment to NRC Comment/Response Table for the MPPB Demolition Plan 4.2 Nuclear Criticalitv Safety Prooram Overview The criticality safety program at the WVDP has been developed to control fissionable materials and potential nuclear criticality hazards in a way that assures that workers, members of the general public, government and personal property, and essential operations are protected from the effects of an inadvertent criticality accident.

Fissionable materials at the WVDP are packaged, handled, and stored in a manner that assures that the potential for an inadvertent criticality is maintained acceptably low.

The criticality safety program assures that environmental, safety, and health protection matters associated with all fissile material operations at the WVDP are comprehensively addressed and receive an objective review, with all identifiable risks reduced to acceptably low levels, and that management authorization of all operations is documented. Consideration is given to all potential criticality hazards associated with fissionable material operations.

Criticality safety at the WVDP is achieved through the application of administrative controls. Evaluations have shown that there is no credible potential for an inadvertent criticality associated with site activities when fissile materials are packaged in conformance with site administrative controls.

Administration of the criticality safety program at the WVDP is through the CHBWV Environmental, Safety, Health and Quality(ESH&Q)organization. The ESH&Q Manager is responsible for monitoring and implementing nuclear criticality safety requirements and for assisting operating management in developing programs and plans for maintaining nuclear criticality safety by regular evaluations and assessments in work areas. The ESH&Q Manager is responsible for developing and maintaining the criticality safety program manual and for criticality safety training.

Additional responsibilities of the ESH&Q Manager are listed in WVDP-162, WVDP Nuclear Criticality Safety Program Manual.

The Criticality Safety Engineer(CSE)is responsible for performing nuclear criticality safety evaluations for activities conducted at the WVDP. In addition, the CSE provides programmatic evaluation to ensure that fissile materials are packaged in a manner that protects worker health and safety and the environment, and that nuclear criticality safety evaluations are performed to identify potential accumulations of fissile material during production, storage, transport, and handling. The CSE is responsible for developing controls for fissile material accumulations to reduce the risk of accidental criticality.

The WVDP is supported by two CSEs that have been qualified per a DOE-approved qualification standard that was developed to meet the requirements of DOE O 420.1 C, Facility Safety, and guidance of ANSI/ANS-8.26, Criticality Safety Engineer Training and Qualification Program. WVDP criticality safety engineers are integrated into site work planning via the WVDP Integrated Safety Management System, which ensures that appropriate hazard control specialists are involved in all site work planning activities.

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Figure XX Vitrification Facility and Main Plant Process Building Following Demolition Dark Gray Represents Cell Floors that were Grouted Teal Green Represents Area Not Grouted Vitrification Facility Approximate ground level

{nominal 100 +/- 3-ft reference elevation)

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